Personal clients

20/04/18

Collection of personal data

Our policy is to collect only the personal data necessary for specified purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.
Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use.
Given the diversity of the services we provide to personal clients (click here for information on our services), we process many categories of personal data, including as appropriate for the services we are providing:

  • Contact details;
  • Business activities;
  • Family information;
  • Income, taxation and other financial-related details; and
  • Investments and other financial interests.

For certain services or activities, and when required by law or with an individual's consent, we may also collect special categories of personal data.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.

Use of personal data

We use personal data for the following purposes:

  • Providing professional services

We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables. For example, we need to use personal data to provide an individual with tax, social security advice or immigration services.

  • Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:

  • managing our relationship with clients;
  • developing our businesses and services (such as identifying client needs and improvements in service delivery);
  • maintaining and using IT systems;
  • hosting or facilitating the hosting of events; and
  • administering and managing our website and systems and applications.
  • Security, quality and risk management activities

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures.

  • Providing our clients with information about us and our range of services

In accordance with applicable law, we use client contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.

  • Complying with any requirement of law, regulation or a professional body of which we are a member

As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

Legal basis for processing

If the processing of personal data referred to in this section is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of service, the processing is based on contractual lawful basis. If the processing of data is necessary for complying with a legal obligation such as complying with tax law obligations or necessity to evidence and document professional services provided, the processing will be based on the legal obligation. If personal data are processed for the other purposes specified above we will rely on the legitimate interest basis or the consent, if we asked the data subject for the consent.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).
In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services does not exceed 10 years.